"For what is
the crime of
burglarizing
a bank,
compared
with the
crime of
building
one?" --Bertolt
Brecht

24/07/08 "The
Nation"
-- - The
Hearing:
Last week in
Washington
we got a
rare look
inside the
global
private
banking
industry,
whose high
purpose it
is to gather
up the
assets of
the world's
wealthiest
people and
many of its
worst
villains,
and shelter
them from
tax
collectors,
prosecutors,
creditors,
disgruntled
business
associates,
family
members and
each other.

Thursday's
standing-room-only
hearing on
tax haven
banks and
tax
compliance
was held by
the US
Senate's
Permanent
Subcommittee
on
Investigations,
chaired by
Michigan
Senator Carl
Levin, a
regular
critic of
tax
havens--except
when it
comes to
offshore
leasing
companies
owned by US
auto
companies.
He presented
the results
of his
Committee's
six-month
investigation
of two of
Europe's
most
venerable
financial
institutions--LGT
Group,
the largest
bank in
Liechtenstein
and the
personal
fiefdom of
Crown Prince
Hans-Adam II
and the
royal
family, with
more than
$200 billion
in client
assets; and
UBS,
Switzerland's
largest bank
and the
world's
largest
private
wealth
manager,
with $1.9
trillion in
client
assets and
nearly
84,000
employees in
fifty
countries,
including
32,000 in
the United
States.

The
theatrics
included
videotaped
testimony by
Heinrich
Kieber, a
Liechtenstein
computer
expert in a
witness
protection
program with
a
$7 million
bounty
on his head,
for
supplying a
list of at
least
1, 400 LGT
clients--some
say more
than
4,500--to
tax
authorities
in Europe
and the
United
States; two
former
American
clients of
LGT, who
took the
Fifth
Amendment;
Martin
Liechti,
head of UBS
international
private
banking for
North and
South
America,
who'd been
detained in
Miami since
April, and
who also
took the
Fifth;
Douglas H.
Shulman, our
sixth IRS
commissioner
in eight
years, who
conceded
that
offshore tax
evasion must
be a
"serious,
growing"
problem even
though the
IRS has no
idea how
large it is;
and Mark
Branson, CFO
of UBS's
Global
Wealth
Management
group, who
apologized
profusely,
pledged to
cooperate
with the IRS
(within the
limits of
Swiss
secrecy) and
surprised
the
Committee by
announcing
that UBS has
decided (for
the third
time since
2002) to
"exit" the
shady
business of
providing
new secret
Swiss
accounts to
wealthy
Americans.

There were
also several
other
potential
witnesses
whose
importance
was
underscored
by their
absence.
Peter S.
Lowy, of
Beverly
Hills,
another
former LGT
client who'd
been
subpoenaed,
is a key
member of
the
Westfield
Group,
the world's
largest
shopping
mall
dynasty,
which
operates
fifty-five
US malls and
118 others
around the
world, is
worth more
than $12.4
billion,
holds the
lease on the
World Trade
Center, has
many other
properties
in Australia
and Israel,
and was
recently
awarded a $3
billion
project for
the UK's
largest
shopping
mall, in
time for the
2012
Olympics.
His lawyer,
the renowned
Washington
fixer
Robert S.
Bennett,
reported
that Lowy
was "out of
the country"
and would
appear
later,
probably
also just to
take the
Fifth.
Perhaps he
traveled to
Australia,
where his
family is
also
reportedly
facing an
LGT-related
tax audit.
(Bennett's
law partner,
David Zornow,
the head of
Skadden,
Arps' White
Collar Crime
practice,
represents
UBS's
Liechti.)
Steven
Greenfield,
a leading
New York
City toy
vendor whose
business had
been
personally
recruited by
the Crown
Prince's
brother,
went AWOL
and did not
bother to
send a
lawyer. LGT
Group
declined to
follow UBS's
contrite
example and
also failed
to appear.

Also missing
from the
roster were
two
prominent
UBS
executives:
Robert Wolf,
CEO of UBS
Americas,
who has
bundled more
than
$370,850 for
Barack Obama
so far this
year, making
UBS his
fifth-largest
corporate
donor; and
former Texas
Senator Phil
Gramm, vice
chairman of
UBS
Securities
LLC, a
leading
lobbyist for
UBS until
March and,
until
recently,
John
McCain's
senior
economics
adviser.
While they
were on the
subject of
offshore
abuses, the
Senate might
also have
wanted to
depose
former top
McCain
fundraiser
James
Courter,
who also
resigned
last week,
after it was
disclosed
that his
telecom
firm, IDT,
had been
fined $1.3
million by
the FCC for
using a
haven
company in
the Turks
and Caicos
to pay
bribes to
former
Haitian
President
Jean-Bertrand
Aristide.

While
neither of
these UBS
executives
have been
directly
implicated
in the tax
scandal,
both might
reasonably
be
questioned
about
precisely
what the
rest of UBS
in the
States knew
about the
Swiss
program,
what it
implies for
US tax
policy, and
whether
those who
complain
about UBS's
knowing
facilitation
of tax fraud
are
just whining.

The
Cases:
This crowded
docket,
combined
with the UBS
mea culpa,
almost
distracted
us from the
sordid
details of
the Levin
Committee's
actual
findings.

UBS:
UBS opened
its first
American
branch in
1939, and
for all we
know, has
likely been
facilitating
tax fraud
ever since,
but the
Senate
investigation
focused only
on 2000 to
2007. During
this period,
even as UBS
was sharply
expanding
its onshore
US
operations
by acquiring
Paine
Webber,
expanding in
investment
and retail
banking, it
also mounted
a top-secret
effort to
recruit
wealthy
Americans,
spirit their
money to
Switzerland
and other
havens and
conceal
their assets
from the
IRS.

This
program,
aimed at
people with
a net worth
of $40
million to
$50 million
each, was
staffed by
fifty to
eighty
senior
calling
officers and
1,000 client
advisors.
Based in
Zurich,
Geneva, and
Lugano, each
officer made
two to ten
surreptitious
trips per
year to the
United
States,
calling on
thirty to
forty
existing
clients per
visit and
trying to
recruit new
ones by
attending
HNW (high
net worth)
watering
holes like
Miami's Art
Basel and
the UBS
Regatta in
Newport. By
2007, this
program had
garnered
20,000
American
clients,
with
offshore
assets at
UBS alone
worth $20
billion.

To achieve
these
results, UBS
established
an elaborate
formal
training
program,
which
coached
bankers on
how to avoid
surveillance
by US
customs and
law
enforcement,
falsify
visas,
encrypt
communications,
secretly
move money
in and out
of the
country and
market
security
products
even without
broker/dealer
licenses.

Meanwhile,
back in
2001, UBS
had signed a
formal
"qualified
intermediary"
agreement
with the US
Treasury.
Under this
program, it
agreed
either to
withhold
taxes
against
American
clients who
had Swiss
accounts and
owned US
stocks, or
disclose
their
identities.
However,
when UBS's
American
clients
refused to
go along
with these
arrangements,
the bank
just caved
in and lied
to the US
government.
Eventually,
it concealed
19,000 such
clients,
partly by
helping to
form
hundreds of
offshore
companies.
This cost
the US
Treasury an
estimated
$200 million
per year in
lost taxes.

In early
July 2008, a
US court
approved a
"John Doe"
subpoena for
UBS,
demanding
the
identities
of these
19,000
undisclosed
clients.
However, as
of last
week's
Senate
hearing, UBS
has refused
to disclose
them. While
it maintains
that it is
no longer
accepting
new Swiss
accounts
from
Americans,
it is also
insisting on
the
distinction
between "tax
fraud" and
"tax
evasion,"
reserving
full
disclosure
only for
cases
involving
criminal tax
fraud, which
is much
harder to
prove under
Swiss law.
This means
it may be
difficult to
ever know
whether it
has kept its
commitments.

Ultimately
UBS got
caught, not
by virtue of
diligent law
enforcement,
much less
the Senate's
investigation,
but by sheer
accident. In
late June,
Bradley
Birkenfeld,
a senior
private
banker who'd
worked with
UBS from
2001 until
late 2005
out of
Switzerland,
and then
continued to
service the
same clients
from Miami,
pleaded
guilty to
helping
dozens of
wealthy
American
clients
launder
money. His
name
surfaced
when his
largest
client, Igor
Olenicoff, a
Russian
émigré
property
developer
from
Southern
California,
was
accidentally
discovered
by the IRS
to be
reporting
much less
income tax
than he
needed to
justify his
$1.6 billion
measurement
on the
Forbes 400
list of
billionaires.

With
Birkenfeld's
help,
Olenicoff
succeeded in
parking
several
hundred
million
dollars' of
unreported
assets
offshore--including
millions in
accounts
controlled
by a
Bahamian
company that
he said had
been set by
former
Russian
Premier
Boris
Yeltsin.
Ultimately,
Olenicoff
settled with
the IRS for
$52 million
in back
taxes, one
of the
largest tax
evasion
cases in
Southern
California
history, and
also agreed
to
repatriate
$346 million
from
Switzerland
and
Liechtenstein.
In theory he
faced up to
three years
of jail
time,
but--following
standard US
practice of
going easy
on
big-ticket
tax evaders
who have no
"priors"--he
received
only two
years
probation
and three
weeks of
community
service.

As noted,
Olenicoff
also gave up
his UBS
private
bankers,
including
Birkenfeld,
who plead
guilty in
June to
facilitating
tax fraud
and is now
awaiting
sentencing--the
first US
prosecution
of a foreign
private
banker in
history. It
was
Birkenfeld's
revelations,
in turn,
that led to
the
disclosure
of UBS'
program for
wealthy
Americans,
and at least
one-half of
the Senate
investigation.

The most
important
point is
that this
entire
program
would
clearly have
been
impossible
without the
knowledge
and approval
of the
bank's most
senior
officials in
Switzerland,
and probably
some senior
US
executives
as well --
although the
committee
did not
press this
point. As
former UBS
CEO Peter
Wuffli once
said, "A
company is
only as
ethical as
its people."
From this
standpoint,
we have
reason to be
concerned
that UBS's
behavior may
repeat
itself, so
long as so
many of
these same
senior
executives
remain in
place.

LGT:
For all its
pretensions
to nobility,
Liechtenstein
is
well-known
in the trade
as the
"place for
money with
the stains
that won't
come out," a
flexible
jurisdiction
whose
"trusts" and
"foundations"
are basic
necessities
for everyone
from
Colombian
drug lords
and the
Saudi royals
to the
Suhartos,
Marcoses,
Russian
oligarchs
and Sicilian
mafia.

As detailed
by the
Senate
investigation,
LGT Group
has
certainly
lived up to
this
reputation
in the US
market. It
maintained a
program that
was, if
anything,
even more
sophisticated
and discreet
than that of
UBS for
large
fortunes.
Among its
specialties:
setting up
conduit
companies in
bland places
like Canada,
allowing
clients to
transfer
money
without
attracting
attention;
leaving the
designation
of
"beneficiaries"
up to
corporations
controlled
by potential
beneficiaries
themselves,
a neat way
of avoiding
"know your
customer"
rules;
rarely
visiting
clients at
home, let
alone
mailing,
e-mailing or
phoning
them,
certainly
never from a
Liechtenstein
post office,
Internet
address or
area code;
shifting the
names of
trust
beneficiaries
to very old
folks just
before death
to make it
look like a
repatriation
of capital
was an
inheritance.

In terms of
precise
trade craft,
indeed, LGT
had it all
over UBS. It
only really
got caught
red-handed
when it
tried to
modernize
and trusted
Heinrich
Kieber,
a fellow
citizen and
IT expert
,who turned
out to be
either a
valiant
whistleblower,
a well-paid
extortionist
(he was paid
$7.5 million
by the
German IRS
alone for
his DVDs),
or both.

Implications:
So what do
we learn
from all
this? Many
will
consider
these
revelations
shocking.
After all,
just as the
US
government
is facing a
$500 billion
deficit,
millions of
Americans
are fighting
to save
their homes,
cars and
college
educations
from the
consequences
of predatory
lending, and
inequalities
of wealth
and income
are greater
than at any
time since
the late
1920s, we
learn that
for decades,
the world's
largest
banks have
been helping
wealthy
Americans
steal
billions in
tax revenues
from the
rest of us.
At the very
least, this
suggests
that it may
be time to
put the
issue of
big-ticket
tax evasion,
offshore and
on, back on
the front
burner. But
we also need
historical
perspective.
Those who
have studied
this subject
for decades
also realize
that
achieving
reform in
this arena
is not a
matter of a
few criminal
prosecutions.
It is a
continuous
game,
requiring
persistence
and constant
adaptations
to the
opponents,
because we
are playing
against some
of the
world's most
powerful
vested
interests,
with huge
fortunes at
stake.

After all,
offshore tax
evasion by
wealthy
Americans is
hardly new.
For example,
in May 1937,
Treasury
Secretary
Henry
Morgenthau
Jr. wrote a
lengthy
letter to
Franklin
Delano
Roosevelt,
explaining
why tax
revenues had
failed to
meet his
expectations
despite a
sharp rise
in tax
rates. Some
rich folks
didn't mind
paying up,
given the
hard times
so many
Americans
were facing
during the
Depression.
As Edward
Filene, the
Boston
department
store
magnate,
famously
remarked,
"Why
shouldn't
the American
people take
half their
money from
me? I took
all of it
from them."
However,
according to
Morgenthau,
many other
rich people
busied
themselves
inventing
new ways to
dodge taxes,
notably by
secreting
funds
offshore in
brand new
havens like
the Bahamas,
Panama
and...
Newfoundland!

Scroll
forward to
the Castle
Bank and
Trust case
of the early
1970s, when
another IRS
investigation
of offshore
banking
disclosed a
list of
several
hundred
wealthy
Americans
who'd set up
trusts in
the Bahamas
and Cayman
Islands.
Just as the
investigation
was picking
up steam and
the names
were about
to be
publicized,
a new IRS
Commissioner
came in and
shut it
down--officially
because the
otherwise-lawless
Nixon
Administration
suddenly got
concerned
about due
process. Few
names on the
list--a copy
of which
appears in
my
forthcoming
book,
Pirate
Bankers,
were ever
investigated.

Scroll
forward now
to the late
1990s, when
the
Organization
for Economic
Cooperation
and
Development
(OECD), the
European
Union and
the US
Treasury
once again
became
excited
about
offshore tax
havens. As
the EU
launched its
"savings
tax
directive"
on
cross-border
interest, a
Cayman
banker
surfaced to
report that
more than 95
percent of
his nearly
2,000
clients were
Americans,
and the IRS
discovered 1
million to 2
million
Americans
using
credit cards
from
offshore
banks.
Meanwhile,
the OECD's
favorite
tool became
the
"blacklist."
A list of
thirty-five
to forty
"havens" was
evaluated on
the basis of
abstract
criteria
like the
quality of
anti-money
laundering
programs and
the
willingness
to negotiate
information
sharing
agreements.

Unfortunately
this "name
and shame"
approach
didn't have
much
success.
First, the
OECD had no
success
against
jurisdictions
like Monaco,
Andorra and
Liechtenstein
that are
basically
shameless.
Second, the
OECD's
definition
of "haven"
was highly
selective.
It omitted
many
emerging
havens like
Dubai, the
Malaysian
island of
Labuan,
Estonia,
Singapore
and
Denmark,
whose
importance
has recently
increased.
As we'll
see, it also
ignored the
role of
major
onshore
havens like
London and
New York,
which have
been very
attractive
to the
world's
non-resident
rich,
especially
from the
developing
world.

Third,
blacklisting
havens
focused on
the wrong
dimension.
As Senator
Levin's
hearing has
underscored,
the real
problem is a
global
pirate
banking
industry
that cuts
across
individual
havens, and
includes
many of our
largest,
most
influential
commercial
and
investment
banks, hedge
funds, law
firms and
accounting
firms. From
their
standpoint,
it doesn't
much matter
whether a
particular
haven
survives, so
long as
others turn
up to take
their place
in providing
anonymity,
security and
low-tax
returns. Up
to now,
despite
blacklisting,
the supply
of new
tax-haven
vehicles has
been very
elastic.

On the other
hand, as the
UBS and LGT
cases show,
the dominant
players in
global
private
banking are
relatively
stable
institutions--which
makes sense,
given their
clients'
need for
stable
sanctuaries.
This
suggests
that it
makes more
sense to
focus on
regulating
institutions
than
regulating
or
blacklisting
physical
places.

Until the
UBS case,
this seemed
to be much
more
difficult
than, say,
beating up
on some tiny
and distant
sultry
island for
shady
people. Even
now, after
the
Birkenfeld
case
supplied the
first
private
banker
prosecution,
we have yet
to see the
first
criminal
prosecution
of a
top-tier
private
bank--apart
from
BCCI in
the early
1990s, which
had already
failed and
was hardly
top-tier.

This is not
because of a
shortage of
despicable
behavior.
For example,
UBS, like
most of its
competitors
in global
private
banking, has
a long
history of
engaging in
perfidious
behavior,
apologizing
for it and
then turning
back to the
future. This
includes
UBS's
involvement
in South
Africa's
apartheid
debt and the
accounts
scandals of
the 1980
involving
the Marcos
family;
Benazir
Bhutto,
Mobutu Sese
Seko,
Holocaust
victims and
Nigerian
dictator
Sani Abacha
of the
1990s; the
2001
Enron
bankruptcy
and the
Menem
scandal; the
2003
Parmalat
scandal;
the
2004-2006
Iran/Cuba/Saddam
funds
transfers
scandal,
for which it
was fined
$100 million
by the
Federal
Reserve; the
2008
Massachusetts
securities
fraud case;
and now the
Birkenfeld
matter.
Furthermore,
as the
committee
report
noted, UBS
has a
history of
violating
even its own
policies.
From this
angle,
unapologetic
LGT is at
least not
hypocritical.

It is also
well to
remember
that UBS and
LGT are
hardly the
only global
private
banks
involved in
recruiting
wealthy
clients to
move money
offshore.
The
committee
report
indicates a
long list of
other banks
that also
provided
offshore
services to
American
clients
involved in
the UBS and
LGT
cases--including
Citibank
(Swiss),
HSBC,
Barclays
(Birkenfeld's
original
employer),
Credit
Suisse,
Lloyds TSB,
Standard
Chartered,
Banque du
Gotthard,
Centrum,
Bank Jacob
Safra and
Bank of
Montreal. In
addition,
there are
dozens of
other non-US
and US banks
that are
also active
in the
offshore US
private
banking
market. This
suggests the
shortcomings
of a
case-by-case
prosecutorial
approach,
and the
value of
designing
regulations
to improve
behavior and
provide
ongoing
feedback
about
taxpayer
compliance.

In
principle,
one can
imagine many
such
improvements
in
regulation,
assuming a
compliant
Congress.
For example,
as proposed
in the
Stop Haven
Abuses Act,
introduced
in 2006 and
revised in
February
2007 by
Senators
Levin,
Coleman and
Obama, there
would be a
rebuttable
presumption
that
offshore
shell
corporations
and trusts
are owned by
those who
establish
them. This
would
eliminate
the "Q.I.
rule"
exception,
which
allowed
hundreds of
UBS clients
to avoid
reporting to
the IRS
simply by
moving their
assets to
into shell
companies.

We could
also
institute
many other
changes,
including an
increase in
the
painfully
short
three-year
statute of
limitations
for
investigating
and
proposing
changes in
offshore tax
liabilities;
tightening
up on
anti-money
laundering
legislation;
levying
withholding
taxes
against
hedge funds;
raising the
penalties
for abusive
tax
shelters,
and
requiring
banks that
open
offshore
entities for
US clients
to report
them to the
US Treasury.

Key
Tasks:
However,
most of
these
proposed
rule changes
have the
flavor of
stopgaps,
technical
gimmicks
that are
still far
too focused
on
individual
taxpayers
rather than
the private
banking
industry--the
advisers,
enablers and
systems
operators.
If we're
right that
this
industry had
become an
unregulated,
untaxed
black
hole--a
multibillion-dollar
global
"bad"--we
need to
focus on two
key tasks.

The first is
to create
appropriate
incentives
for the
global
private
banking
industry to
do the right
thing. We
need to find
ways to tax
the behavior
of
tax-evading
institutions,
their CEOs,
senior
managers and
even
shareholders,
to punish
them for
more
misbehavior,
and perhaps
also reward
them for
bringing the
money home
with a brief
one-time tax
amnesty. In
the short
run, there
have to be
more Bradley
Birkenfelds,
more
exposés, and
more
penalties
for banks
and bankers
alike. Mere
apologies,
however
heartfelt,
should not
be enough.

The second
challenge is
to organize
a global
alliance
around this
issue. This
is more
difficult,
although
steps are
already
being taken.
Global
organizations
like Tax
Justice
International,
Oxfam GB,
Friends of
the Earth,
Global
Witness and
Christian
Aid are
converging
on a new
global
campaign
around the
issue of
havens and
offshore tax
evasion.
They've been
enlisting
support for
this effort
from
countries
like Norway,
Chile,
Brazil,
Spain and
France,
organizations
like the
UNDP, the
World Bank
and even the
International
Monetary
Fund.

This is very
exciting,
but the
organizers
face one
critical
problem--the
fact there
are serious
conflicts of
interest
among
developed
and
developing
countries.
The fact is
that the
United
States, the
UK and other
developed
countries
not only
lose tax
revenue to
haven
banking;
they also
profit from
it, because
their own
banks are so
deeply
engaged in
it,
especially
when it
involves
developing
countries.

Back in
April 1986,
this author
broke the
story that
Citibank was
actually
taking far
more capital
out of Latin
America and
other
developing
countries
than it was
lending to
them,
despite its
reputation
as the
largest
Third World
lender.
Indeed, the
business of
helping
Third World
elites
decapitalize
their own
countries
had become
so large and
lucrative
that Citi's
private
banking
group was
the bank's
single most
profitable
division.

To achieve
that feat,
Citigroup
resorted to
skullduggery
and the
flouting of
local laws
all over the
planet. This
included
repeatedly
sending
teams of
private
bankers
undercover
to countries
like Brazil,
Argentina,
and
Venezuela;
helping to
set up
thousands of
shell
companies
and bank
accounts in
offshore
havens and
secretly
transferring
funds to
them;
teaching its
clients
money-laundering
tricks like
mis-invoicing
and
back-to-back
loans;
designing
ways to
communicate
with clients
that kept
their
financial
secrets
safe; and
overall,
concealing
vast sums of
flight
capital from
Third World
tax
authorities
(and their
competitors),
while
lobbying
Congress to
insure that
any foreign
capital that
arrived in
the United
States
enjoyed
near-zero
taxes and
near-Swiss
secrecy. For
a time the
resulting
tax breaks
and lax
banking
rules that
applied to
"nonresident
aliens" from
other
countries
made the
United
States, in
effect, one
of the
world's
largest tax
havens.

In short,
from the
1970s to the
1990s, banks
like
Citigroup,
BankAmerica
and JP
Morgan Chase
(and UBS,
Credit
Suisse, RBS,
Paribas and
Barclays
etc.) were
behaving
throughout
the Third
World just
as badly as
UBS has
recently
been
behaving
here. And
their very
success laid
the
foundations
for the
global
private-haven
banking
industry
with which
the IRS is
now
struggling.

At the time,
it seemed
that their
behavior was
hurtful
mainly to
the
developing
world, which
wasn't
strong
enough to
hold Senate
hearings and
put
Citibankers
in jail. But
lately it
has become
clear that
the system
has grown
large enough
to consume
its
creators.

In the last
thirty
years,
fueled by
the
globalization
of financial
services,
lousy
lending,
capital
flight and
mind-boggling
corruption,
a relatively
small number
of major
banks, law
firms,
accounting
firms, asset
managers,
insurance
companies
and hedge
funds have
come to
launder and
conceal at
least $10
trillion to
$15 trillion
of private
untaxed
anonymous
cross-border
wealth.

Rich people
the world
over,
including
tens of
thousands of
wealthy
Americans,
are now free
to opt in to
this
sophisticated,
secretive,
utterly
unprincipled
global
private
banking
industry.
They can
become, in
effect,
residents of
nowhere for
tax
purposes,
citizens of
a brave new
virtual
country,
which offers
its
inhabitants
unprecedented
freedom from
the taxes,
regulations
and moral
restraints
that the
rest of us
take for
granted.
They wield
enormous
political
influence
even without
paying
taxes,
merely by
making
contributions,
threatening
to withhold
them--or
better yet,
threatening
to abscond
with their
capital
unless
certain
conditions
are met. In
a sense,
this is the
ultimate
libertarian
pipe dream:
representation
without
taxation.
But it is a
nightmare
for the rest
of us, and
we must
design and
organize our
way around
it.

James S.
Henry is a
New
York-based
investigative
journalist
who has
written
widely on
the problems
of tax
havens,
debt, and
development.
His most
recent book,
The Blood
Bankers
(Basic
Books,
2005),
examined
where the
money went
that was
loaned to
eight
developing
nations. His
forthcoming
book, Pirate
Bankers
(2009),
examines the
history and
structure of
the global
private
banking
industry

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